JAMNALAL vs RADHESHYAM — C.A. No. 3340/1998

Case Summary: JAMNALAL v. RADHESHYAM Court Decision: The Supreme Court allowed the landlords' appeal and ordered eviction of the tenant for non-payment of rent arrears. Key Issue: Whether a court can evict a tenant under Section 12(1)(a) of the M.P. Accommodation Control Act, 1961 for rent default without first determining provisional rent under Section 13(2), when the tenant disputes the arrears amount but admits the rent rate. Holding: The Court held that provisional rent fixation is required only when the rent rate itself is disputed. Where the rate is admitted (Rs.60/month here) but arrears are disputed on the claim that rent was paid, the tenant must still comply with deposit obligations under Section 13(1). Since the trial court found the tenant forged rent receipts and failed to deposit arrears or future rent, eviction was warranted. The tenant was directed to vacate by October 31, 2000, and pay outstanding rent arrears within four weeks. This case analysis is maintained by casestatus.in based on publicly available court records.